A Quick Reference To The Use Of Prior Convictions
| by Robert C. Bonsib, Esq. and Megan E. Coleman, Esq.
carries probative value on the issue of
truth and veracity of the witness, should
the evidence be admitted.
In Jackson v. State, 340 Md. 7-5, 71213 (1995), the COA noted the three-part
test analysis that is applicable under Rule
5–609.
T
his article provides a quick guide to
what prior convictions may be used
for impeachment purposes, a review of
what factors the court must consider in
determining whether a prior conviction
may be used for impeachment purposes,
and discusses selected issues in appellate
decisions relevant to Maryland Rule
5-609.
In State v. Westpoint, 404 Md. 455, 47379 (2008), the Court of Appeals (COA)
highlighted some of the issues presented
when the question before the trial court
is related to the proper use of prior
convictions noting that in Prout v State,
311 Md. 348, 358-63 (1988), it observed
that it is difficult to draw distinct lines
on what crimes may be used to impeach.
The Maryland law on this subject may be
generally summarized as holding that to
be admissible for impeachment purposes
a conviction must be either a felony at
common law or a crimen falsi and thus
infamous, or a lesser crime bearing upon
the witness’s credibility. Stated another
way, crimes, other than those that are
infamous, whether misdemeanors or
statutory felonies, fall into the class
of lesser crimes and may or may not
reflect on one’s tendency to be truthful.
If the crime being offered to impeach
says nothing about the likelihood of
the witness’s propensity to be truthful
under oath, it is irrelevant on that issue
and should not be admitted. If the prior
conviction passes this relevancy test,
then the trial court must determine if its
probative value outweighs its prejudicial
effect. In other words, because evidence
is legally admissible does not necessarily
require its admission. Only if the trial
judge, in the exercise of his/her discretion,
feels that the prior conviction rationally
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First, a conviction must fall within the
eligible universe to be admissible. This
universe consists of two categories: (1)
infamous crimes, and (2) other crimes
relevant to the witness’s credibility. Md.
Rule 5–609(a).
Second, if the crime falls within one of
these two categories, the proponent must
establish that the conviction is less than
fifteen years old. Md. Rule 5–609(b).
Finally, the trial
probative value
evidence against
prejudice to the
5–609(c).
court must weigh the
of the impeaching
the danger of unfair
defendant. Md. Rule
The COA continued that with respect to
impeachment, it has said that impeachment
with a prior conviction can be used “to
assist the fact finder in measuring the
credibility of the defendant,” Ricketts
v. State, 291 Md. 701, 703 (1981), at
the same time preventing “a jury from
convicting a defendant based on his past
criminal record, or because the jury thinks
the defendant is a bad person.” Jackson,
340 Md. at 715. The COA further
reminded that it has imposed limitations
on the use of past convictions “in an effort
to discriminate between the informative
use of past convictions to test credibility,
and the pretextual use of past convictions
where the convictions are not probative
of credibility but instead merely create
a negative impression of the defendant,”
because:
of criminal activity and therefore is
not entitled to a favorable verdict.
Such evidence may detract from
careful attention to the facts, despite
instructions from the court, influencing
the jury to conclude that if the defendant
is wrongfully found guilty no real harm
is done. Where the crime for which
the defendant is on trial is identical or
similar to the crime for which he has
been previously convicted the danger
is greater, as the jury may conclude
that because he did it before he most
likely has done it again. The net effect
of such evidence is often to discourage
the defendant from taking the stand.
Thus, the role of the trial judge takes
on added importance. It becomes his
function to admit only those prior
convictions which will assist the jury
in assessing the credibility of the
defendant. The trial judge must weigh
the probative value of the convictions
against the prejudice to the defendant
in asserting his defense.
Id. at 715–16, quoting Ricketts v. State,
291 Md. 701, 703–04 (1981).
To begin the discussion, we must first
identify those offenses that fall into
the universe of offense that may be
impeachable. The following Guide
provides a quick index as to which
offenses pass Step One as to the first test
of impeachment admissibility.
The danger in admitting prior
convictions as evidence to impeach
the defendant stems from the risk of
prejudice. The jury may improperly
infer that the defendant has a history
Page 6
September 2014
Thus, the role of the trial judge takes on added importance. It becomes his
function to admit only those prior convictions which will assist the jury in
assessing the credibility of the defendant. The trial judge must weigh the
probative value of the convictions against the prejudice to the defendant in
asserting his defense.
Prior Convictions, Cont’d
Id. at 715–16, quoting Ricketts v. State, 291 Md. 701, 703–04 (1981).
To begin the discussion, we must first identify those offenses that fall into the universe of
offense that may be impeachable. The following Guide provides a quick index as to which
offenses pass Step One as to the first test of impeachment admissibility.
STEP ONE: Is it an Impeachable Offense?
STEP ONE: Is it an Impeachable Offense?
A QUICK REFERENCE
GUIDE TO IMPEACHABLE OFFENSES
A QUICK REFERENCE GUIDE TO IMPEACHABLE OFFENSES
Cure v. State, 421 Md. 300, 324 (2011)
Indecent Exposure
No
Ricketts v. State, 291 Md. 701 (1981)
*common law felony
Manslaughter
Yes
Cure v. State, 421 Md. 300, 324 (2011)
Arson
Yes
Assault
No
State v. Duckett, 306 Md. 503, 512 (1986)
Assault on a Police Officer
No
Thurman v. State, 211 Md.App. 455 (2013)
Assault with Intent to Murder
No
Thurman v. State, 211 Md.App. 455 (2013)
Burglary
Yes
*common law felony
Mayhem
Murder
Distribute No
Drugs
Yes
Cure v. State, 421 Md. 300, 324 (2011)
Cure v. State, 421 Md. 300, 324 (2011)
*common law felony
*common law felony
to
Cure v. State, 421 Md. 300, 324 (2011)
*common law felony
Fulp v. State, 130 Md.App. 157 (2000)
Conspiracy
Yes
Obstruction of Justice
Yes
Garitee v. Bond, 102 Md. 379 (1905)
Wallach v. Bd. Of Ed., 99 Md. App. 386, 391-92
Fulp v. State, 130 Md.App. 157 (2000)
(1994)
Prout v. State, 311 Md. 348, 360 (1988)
Disorderly Conduct
No
Morales v. State, 325 Md. 330, 339 (1992)
Drug Distribution (and PWID)
Yes
Summers v. State, 152 Md.App. 362, cert. denied, 378
Fulp v. State, 130 Md.App. 157 (2000)
Md. 619 (2003)
Prout v. State, 311 Md. 348, 360 (1988)
State v. Giddens, 335 Md. 205, 217 (1994)
Drug Manufacturing
Yes
Carter v. State, 80 Md.App. 686, 693 (1989)
Drug Possession
No
Morales v. State, 325 Md. 330, 339 (1992)
Lowery v. State, 292 Md. 2, 2 (1981)
Cason v. State, 66 Md.App. 757, 774 (1986)
Embezzlement
Yes
Perjury
Yes
Prostitution
No
Matthews v. State, 68 Md.App. 282 (1986)
Rape
Yes
Cure v. State, 421 Md. 300, 324 (2011)
*common law felony
Resisting Arrest
No
Banks v. State, 213 Md.App. 195 (2013)
Robbery
Yes
Facon v. State, 144 Md. App. 1, reconsideration
Garitee v. Bond, 102 Md. 379 (1905)
denied, cert. granted and reversed, 375 Md. 435
Fulp v. State, 130 Md.App. 157 (2000)
(2002)
Prout v. State, 311 Md. 348, 360 (1988)
Failure to Register as a Sex No
False Pretense
Cure v. State, 421 Md. 300, 324 (2011)
Correll v. State, 215 Md. App. 483 (2013)
Offender
*common law felony
rd
Yes
Garitee v. Bond, 102 Md. 379 (1905)
Sex Offense 3 Degree
No
State v. Westpoint, 404 Md. 455 (2008)
Sodomy
Yes
Cure v. State, 421 Md. 300, 324 (2011)
Fulp v. State, 130 Md.App. 157 (2000)
Prout v. State, 311 Md. 348, 360 (1988)
False Statement
Yes
Garitee v. Bond, 102 Md. 379 (1905)
Fulp v. State, 130 Md.App. 157 (2000)
Prout v. State, 311 Md. 348, 360 (1988)
Fleeing from a Police Officer
No
Thurman v. State, 211 Md.App. 455 (2013)
Fraud
Yes
Garitee v. Bond, 102 Md. 379 (1905)
*common law felony
Theft
Yes
Traffic Offenses
No
Morales v. State, 325 Md. 330, 339 (1992)
Treason
Yes
State v. Duckett, 306 Md. 503, 512 (1986)
Garitee v. Bond, 102 Md. 379 (1905)
Fulp v. State, 130 Md.App. 157 (2000)
Prout v. State, 311 Md. 348, 360 (1988)
Prout v. State, 311 Md. 348, 360 (1988)
Yes
Cure v. State, 421 Md. 300, 324 (2011)
*common law felony
Fulp v. State, 130 Md.App. 157 (2000)
Forgery
Garitee v. Bond, 102 Md. 379 (1905)
Garitee v. Bond, 102 Md. 379 (1905)
What is a “conviction” and what may the jury learn about the conviction
Fulp v. State, 130 Md.App. 157 (2000)
A conviction includes:
Prout v. State, 311 Md. 348, 360 (1988)

A plea of nolo contendere followed by a sentence, whether or not the sentence is
suspended

Evidence of juvenile adjudication may be admissible under the Confrontation Clause to
show bias, see Davis v. Alaska, 415 U.S. 308 (1974) and Courts Article § 3-8A-23
The jury may hear about the conviction only as to:
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Page 7

The name of the crime

The time and place of conviction
cont’d on next page...
September 2014
Prior Convictions, Cont’d
What is a “conviction” and what may the
jury learn about the conviction
A conviction includes:
• A plea of nolo contendere
followed by a sentence, whether or not
the sentence is suspended
• Evidence of juvenile adjudication
may be admissible under the
Confrontation Clause to show bias, see
Davis v. Alaska, 415 U.S. 308 (1974)
and Courts Article § 3-8A-23
The jury may hear about the conviction
only as to:
• The name of the crime
• The time and place of conviction
• The sentence received
The jury may not be told the underlying
details of the prior conviction. State v.
Giddens, 335 Md. 205, 222 (1994)
STEP TWO: Additional Prerequisites
to the Admissibility of an Impeachable
Conviction
Rule 5-609 provides threshold bars to the
admissibility of a prior conviction. A prior
conviction is NOT admissible if it is:
• More than 15 years old
• Pending an appeal (or the time for
noting an appeal or filing an application
for leave to appeal has not expired)
• Reversed on appeal
• Pardoned
• Stricken and a probation before
judgment is entered (See Molter v.
State, 201 Md.App. 155 (2011))
STEP THREE: The Probative Value
of the Prior Impeachable Conviction
Must Outweigh the Danger of Unfair
Prejudice to the Witness or Objecting
Party
Rule 5-609 does not provide a per se
ground for admissibility simply because
the prior conviction is within the category
of potentially admissible convictions.
Even in those instances where the prior
conviction passes Steps One and Two, the
trial court must still conduct a balancing
test to determine whether the probative
value of the prior impeachable conviction is
outweighed by its potential unfair prejudice
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to the defendant or a witness. In addressing
how the trial court conducts this weighing
process, the COA identified five factors
for trial judges to consider when weighing
the probative value of a past conviction
against its prejudicial effects:
1) The impeachment value of the
prior crime;
2) The length of time since
the conviction and the witness’s
subsequent history;
3) The similarity between the
past crime and the charged crime
(the similarity between the prior
conviction and the crime for which
a defendant is being tried does not
per se preclude impeachment with
that conviction. Facon v. State, 144
Md.App. 1, 47, 48, 796 A.2d 101
(2002), rev’d on other grounds, 375
Md. 435, 825 A.2d 1096 (2003)).
4) The importance of the witness’s
testimony to the case, and the relative
need for the evidence relevant to the
witness’s credibility; and
5)
The risk of unfair prejudice,
which is particularly high if the
witness sought to be impeached is
the accused, King v. State, 407 Md.
682, 704-06 (2009), and the prior
conviction is for a crime similar to
that for which the accused is on trial.
See Prout v. State, 311 Md. 348, 364
(1998), Jackson v. State, 340 Md. 705,
717 (1995), Cure v. State, 421 Md. 300,
329-31 (2011).
An example of an instance when the trial
court failed to properly conduct such a
weighing occurred in Beales v. State,
329 Md. 263, 273-75 (1993) wherein the
COA concluded that the trial court did
not adequately conduct a balancing of a
14–year–old theft conviction in terms of
the light it might shed on the witness’s
truthfulness against its potentially unfair
prejudice to Beales’ defense. It noted
that the trial court’s elliptical remarks
did not sufficiently demonstrate that it
assessed the relative weights of probative
value and prejudicial danger. First, the
trial court focused largely on the proper
form of the impeaching question, rather
Page 8
than on its possible impact. Second,
the trial court insisted that the State
had a “right” to inform the jury of the
witness’ conviction, a word that suggests
obligatory admissibility of the evidence,
rather than discretionary admissibility
based on the balancing test. Third, the
trial court admitted the evidence knowing
only that the witness had been convicted
of theft, but not knowing when he had
been convicted. The witness testified that
his conviction was fourteen years old only
at the very end of the exchange, after the
trial court had ruled. The remoteness of a
prior conviction is a critical factor to be
weighed in the balance. Here it was not.
As the COA noted as even more
compelling, the Rule places a cap of
fifteen years on prior convictions used to
impeach. Had the witness’s conviction
been sixteen years old, it would have been
barred altogether by the Rule. The trial
court’s failure to ascertain the vintage of
the conviction before deciding the question
indicates strongly that it adhered to the
former law of impeachment permitting
per se use of convictions of infamous
crimes no matter how remote. The COA
was concerned as the trial court let in the
evidence solely because the witness had
been convicted of theft, a crimen falsi and
an infamous crime, as was proper under
the old impeachment statute. The record
thus demonstrated that the trial court did
not appropriately apply the Rule. At the
trial, the prosecution and the defense
presented dramatically different accounts
of the incident leading to Beales’ arrest.
The relative validity of those accounts
depended largely on the credibility of the
witnesses. The witness was a primary
defense eye-witness, the observer closest to
the scene of the altercation. His credibility
was tainted, to a degree that the COA noted
it could not specify without speculating,
by evidence that he was a convicted thief.
The State in its closing argument reminded
the jury of that fact by saying: “Judge [the
witness]. He told you he was convicted of
theft. Why is that important? Not because
he did it, but because he’s been [Beales’s]
friend for ten years and maybe he’s not
telling the truth.” Reviewing the record
before it, the COA held that it could not say,
September 2014
Prior Convictions, Cont’d
beyond a reasonable doubt that evidence of
the [witness’] theft conviction did not sway
the jury that found Beales guilty of battery.
A REMINDER WHEN THE
CONVICTION COMES IN
While criminal law practitioners understand
the limitation the law provides concerning
the use that may be properly made of prior
convictions, the jury needs to be instructed
(assuming as we all are told we must, that
limiting instructions have a real effect in
the real world) that the conviction may be
considered only with regard to the witness’
credibility.
The Maryland Pattern Criminal Jury
Instructions provide a pattern instruction as
to this issue.
MPJI-Cr 3:22 -Impeachment by Prior
Conviction
A. Defendant
You have heard evidence that the defendant
has been convicted of a crime. You may
consider this evidence in deciding whether
the defendant is telling the truth, but for no
other purpose. You must not consider the
conviction as evidence that the defendant
committed the crime charged in this case.
B. Witness
You have heard evidence that [defendant]
has been convicted of a crime. You may
consider this evidence in deciding whether
the witness is telling the truth, but you cannot
consider this evidence for any other purpose.
PRESERVATION OF THE PRIOR
CONVICTION ISSUES
Does the election not to testify fail to
preserve a ruling that a prior conviction
is admissible?In Brown v. State, 373
Md. 234, 243 (2003), the COA held that
when a defendant elects to testify and, in
doing so, testifies affirmatively on direct
examination to the existence of a prior
conviction in order to “draw the sting out”
of that conviction, he or she waives his or
her right to appellate review of the merits of
the trial judge’s prior in limine determination
that the prosecution may use the conviction
for impeachment purposes.
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The holding was revisited by the COA in
Cure v. State, 421 Md. 300, 321-23 (2011), in
which the COA held that when a defendant
elects to testify and, in do so, testifies
affirmatively on direct examination as to the
existence of a prior conviction in order to
“draw the sting out” of that conviction, he
or she does not waive necessarily his or her
right to appellate review of the merits of the
trial judges’ prior in limine determination
that the prosecution may use the conviction
for impeachment purposes.
The limited setting as to when this applies
occurs where (1) the State makes clear
that it intends to offer the conviction if the
defendant testifies, (2) the defendant makes
a clear objection to the evidence, (3) the
court makes a definitive ruling, intended to
be final, that the evidence will be admitted,
and (4) the defendant testifies and, to blunt
the force of the conviction, reveals it on
direct examination.
Here the prosecutor stated explicitly
that “[t]he State would like to bring that
up” (referring to the arson conviction),
satisfying the first prong. As to the
second prong, defense counsel made a
clear objection during argument on the
motion in limine, stating “Yes, Your
Honor, and certainly we would object” to
the trial judge’s ruling “I’d let [the prior
arson conviction] in.” Fulfilling the third
prong, the court made an unequivocal and
definitive ruling allowing the use of the
prior arson conviction for impeachment,
but not the prior attempted murder
conviction, offering nothing that would
lead a reasonable person to believe that the
trial judge would reconsider his decision
on the motion. Moreover, when defense
counsel advised Cure, before he elected to
testify, that his prior conviction would be
admissible for impeachment purposes, the
trial court made no attempt to revisit the
issue. Finally, satisfying the fourth prong,
Cure testified to the conviction under direct
examination in the defense case-in-chief in
an obvious attempt to blunt its force. Thus,
the COA concluded that Cure did not waive
the opportunity to seek appellate review
of the admissibility of his prior arson
conviction for impeachment purposes.
Page 9
An example of where Cure may not be
applicable occurred in Dallas v. State,
413 Md. 569, 573-76 (2010). The COA
instructed that there are the times when
a trial court can and, therefore, should
decide a motion in limine involving a Rule
5–609 issue before the defendant makes
the election. For example, when it is clear
that a prior conviction is ineligible for
impeachment under Rule 5–609, the court
need not hear the defendant’s testimony to
know how to rule on a motion to exclude
that proposed impeachment evidence.
Similarly, the trial court certainly can
recognize when the risk of unfair prejudice
of the proposed impeachment evidence
far outweighs its probative value, no
matter how the defendant might testify.
Moreover, the court may be satisfied that it
has a sufficient basis upon which to make
an in limine ruling without hearing the
defendant’s direct testimony if the court
has learned, through other means, how the
defendant is likely to testify. For example,
a court may hear admissions that the
defense makes during the defense’s
opening statement, or the court may
accept a proffer of the defendant’s direct
testimony. In any of these circumstances,
fairness to the defendant argues in favor
of the trial court’s ruling on the motion
before the defendant elects to testify or
remain silent.
However, in Dallas, the COA indicated
that it remained for it to decide whether
the trial court abused its discretion in
deferring its ruling on his motion in
limine seeking to prohibit the State from
impeaching him with evidence of his
prior felony drug convictions.
During the lengthy discussion on the
subject, the trial court explained that, in
light of the similarity between the pending
charges and the prior convictions, it was
necessary to await Dallas’ testimony before
deciding whether the probative value
of the proposed impeachment evidence
outweighed the danger of unfair prejudice.
To be sure, the trial court was aware that
the defense to the felony charge was to
cont’d on next page...
September 2014
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urt
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Prior Convictions, Cont’d
Kim S. Haskell, D.D.S., P.A.
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